City Boxing Club v. USA Boxing, Inc.

1 CHRISTINE M. EMANUELSON (SBN 10143) [email protected] NICOLE M. HAMPTON (SBN 16090) [email protected] BRIAN PELANDA Pro Hac Vice, California Bar No. 278453 [email protected] HINES HAMPTON PELANDA LLP South 4th Street Las Vegas, Nevada 89101 Tel.: (702) 933-7829 Fax: (702) 947-1709 Attorneys for Defendants Scottsdale Ins. Co. and K&K Ins. Group 10 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA CITY BOXING CLUB, et al., Case No.: 2:23-cv-00708-JAD-DJA Plaintiffs, STIPULATION AND [PROPOSED] v. ORDER EXTENDING TIME FOR RESPONSE AND REPLY REGARDING USA BOXING, INC. dba USA BOXING, et PLAINTIFFS’ MOTION TO COMPEL al., PRODUCTION OF DOCUMENTS AND 17 WITNESS DEPOSITION [DOC. 87] Defendants.

THE PARTIES, by and through undersigned counsel, stipulate and agree to extend the time for Defendants Scottsdale insurance Company and K&K Insurance Group to file their response, and to extend the time for Plaintiffs to file their reply, regarding the Motion to Compel that Plaintiffs filed on June 19, 2025. [See Doc. 87.]

Scottsdale and K&K’s counsel requested this extension because the motion was filed on June 19, 2025, while he was preparing for the trial of another case that was scheduled to begin trial on July 7th in Los Angeles County, and he has advised that he has not had sufficient time to review and prepare a response to the motion.

1 The current deadlines, and proposed new deadlines are as follows: 2 Current Deadline Proposed Deadline 3 Response: July 3, 2025 July 10, 2025 4 Reply: July 10, 2025 July 17, 2025 || Dated: July 1, 2025. Dated: July 1, 2025.

7 /s/ Daniel Price /s/Stephen A. Hess g || Daniel R. Price, Esq. Wing Yan Wong, Esq.

Christopher Beckstrom, Esq. Gordon Rees Scully Mansukhani, LLP || Janice Parker, Esq. 300 S. 4 Street, Suite 1550 Jasmin Stewart, Esq. Las Vegas, NV 89101 || price & BECKSTROM ll 1404 S. Jones Blvd. Stephen A. Hess, Esq.

Las Vegas, Nevada 89146 Law Office of Stephen A. Hess, P.C.

12 Attorneys for Plaintiffs 111 South Tejon, Suite 102 Colorado Springs, CO. 80903 13 Attorneys for USA Boxing, Inc. |! Dated: July 1, 2025.

IS /s/ Brian Pelanda || Christine M. Emanuelson, Esq.

Nicole Hampton, Esq.

17 || Brian L. Pelanda, Esq.

Hines Hampton Pelanda LLP || 400 South 4" Street Las Vegas, NV 89101 Attorneys for Scottsdale Insurance Company, 90 and K&K Insurance Group 22 IT IS ORDERED.

23 \ DANIEL J. ALBREGTS 25 UNITED STATES MAGISTRATE JUDGE 26 DATED: 7/2/2025 CERTIFICATE OF SERVICE I hereby certify that on July 1, 2025, I electronically filed the foregoing document with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the e- mail addresses denoted below under the Electronic Mail Notice List.

I certify under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on July 1, 2025.

/s/ Brian Pelanda Brian Pelanda 12 Electronic Mail Notice List 13 Daniel Price, Esq. ([email protected]) 14 Christopher Beckstrom, Esq. ([email protected]) 15 Wing Yan Wong ([email protected]) 16 Stephen Hess ([email protected])